Despite numerous attempts to cease the "app," Hewlett Packard refused to dismantle the operation and, therefore, continues to perpetuate degrading and derogatory content directly linked to Chubby Checker. The "app" adversely affects Chubby Checker's brand and value and if allowed to continue, will cause serious damage to the Plaintiff's goodwill and will tarnish his image that he has worked to maintain over the last 50 years.